EU Right to Repair Directive: Manufacturer Duties 2026

Since 31 July 2026, the EU Right to Repair Directive (Directive (EU) 2024/1799) has been an operating requirement rather than a policy debate. Each member state applies it through its own national law, so check the transposing act in every country where you sell to consumers. Manufacturers of covered products must repair them on request, within a reasonable time and at a reasonable price, and the duty can apply to units already in customers' hands, not just new sales.

For manufacturers, the real deadline is not legal, it is operational: repair requests become a workflow you must run at production discipline.

This guide covers what the directive requires, who is in scope, and what to set up on the operations side before the requests pile up.

Key Takeaways

• The directive entered into force in July 2024; EU member states must apply their national transposition rules from 31 July 2026. Exact wording varies by country, so check your national text.
• Producers of covered product groups must repair on request within a reasonable time and for a reasonable price, even outside the legal guarantee, and the duty can reach units sold before 2026 if they fall under the ecodesign repairability rules for their product group.
• Anti-repair practices are banned: no contractual, hardware, or software techniques that impede repair unless justified by legitimate and objective factors, and no refusing a repair because a customer or independent shop repaired the product previously.
• Spare parts and tools must be available to repairers at reasonable prices, which turns long-horizon parts logistics and obsolescence planning into a compliance topic.
• When a consumer chooses repair as the remedy under the seller's legal guarantee, the seller's liability period is extended once by 12 months, for sales contracts concluded from 31 July 2026, so repairs done for sellers must be documented and traceable. Clean repair records stop being nice to have.

What the Directive Actually Requires

The core obligations for producers of covered goods:

• Duty to repair: when a consumer requests it, you must repair the product within a reasonable time, free or for a reasonable price. You may lend the consumer a replacement device during the repair, free or for a reasonable fee, and where repair is impossible you may offer a refurbished unit.
• No repair blocking: you cannot use contract clauses, hardware design, or software locks to hinder repair. You cannot block independent repairers from using original, second-hand, compatible, or 3D-printed spare parts that meet product safety and intellectual property rules, unless a restriction is justified by legitimate and objective factors such as protecting intellectual property, and you cannot refuse service because someone else repaired the unit before.
• Spare parts and tools: parts and repair tools must be available at a reasonable price, with repair information accessible to independent repairers.
• Transparency: repairers may give consumers a standardized European Repair Information Form with repair terms, price, and time before they commit. Using the form is optional, but once given, its conditions bind the repairer for 30 calendar days. Manufacturers with a repair duty must also publish indicative prices for typical repairs on a free access website, and a European online platform will route consumers to repairers.
• Guarantee extension: choosing repair over replacement under the legal guarantee extends that guarantee by 12 months.

The covered product groups are those with EU repairability requirements: household washing machines and washer-dryers, household dishwashers, refrigerating appliances, electronic displays, welding equipment, vacuum cleaners, servers and data storage products, mobile phones, cordless phones and slate tablets, household tumble dryers, and goods incorporating light means of transport batteries, such as e-bikes and e-scooters. The list is expected to grow as ecodesign rules expand to more categories.

Why This Is an Operations Problem, Not a Legal Memo

Legal can tell you what "reasonable time" means in your member state. Only operations can deliver it.

A repair obligation at scale looks exactly like a small production line: incoming units must be triaged, diagnosed, quoted (optionally on the European Repair Information Form, whose terms then bind the repairer for 30 calendar days), scheduled to a technician, supplied with parts, tested, and shipped back, with every step timestamped. If your current process for out-of-warranty repairs is an inbox and a spreadsheet, a few hundred requests per month will bury it, and "reasonable time" becomes indefensible.

The manufacturers that handle this well will treat each repair as a work order with a defined workflow: statuses, assignments, parts consumption, test results, and sign-off. That is standard task and work card management, applied to a repair bench instead of a press line.

Spare Parts: The Hard Part

The repair duty is only as good as the parts shelf behind it. Three consequences follow:

• Long-horizon stocking: ecodesign rules already require parts availability for 7 to 10 years after the last unit ships in several categories. The directive adds price reasonableness on top, so you cannot stock minimally and price prohibitively.
• Obsolescence management: components go end-of-life faster than your repair obligation does. You need a tracked process for last-time buys, substitutes, and approved compatible parts. The discipline is the same as spare parts obsolescence management for production equipment.
• Inventory accuracy: every repair consumes parts, and consumption must be logged against the repair for costing and for proving parts availability. Loose stockroom habits show up as compliance gaps. The fundamentals of spare parts management apply unchanged.

There is also a commercial decision hiding here: repair-or-replace economics. With the guarantee extension rewarding repair, the repair vs replace calculation shifts, and you want it made on data, not habit.

The Data Angle: Repair Records Become an Asset

Repairs done as a legal guarantee remedy now extend the seller's liability by 12 months, and repairs under your own repair duty must meet a reasonable time you may need to prove. That means every repair needs a durable, retrievable record: what failed, what was replaced, who did the work, and, where the extension applies, when it ends.

Done properly, that record set is more than compliance. Repair histories per product family are exactly the dataset that reveals design weaknesses, informs parts stocking, and eventually feeds AI-driven failure prediction. But that only works if the records are structured from day one: coded failure modes, standard part numbers, consistent timestamps. Manufacturers who capture repairs as free-text emails will have data no algorithm can rescue. Foundations first, AI second.

Timeline

Duties That Are Easy to Miss

Publish prices and repair information. Manufacturers with a repair duty must let consumers see indicative prices for typical repairs on a free access website (Article 5(5)), and must make information on their repair services available free of charge, in an easily accessible, clear and comprehensible way, for the whole period of the repair duty (Article 6).

Manufacturers outside the EU. If the manufacturer is established outside the EU, the duty passes to its authorized representative in the Union, then to the importer if there is no authorized representative, and then to the distributor if there is no importer. Each of them may subcontract the repair (Article 5(3)).

National law decides the details. Each member state had to adopt its own transposing law by 31 July 2026 and set penalties that are effective, proportionate and dissuasive. Keep a simple table for every country where you sell to consumers: the transposing act, its date of application, the enforcement authority, and the penalties.

FAQ

Does the Right to Repair Directive apply to industrial B2B equipment?

No. The repair duty is owed to consumers, meaning private individuals buying outside their trade or profession, and only for the product groups listed in Annex II. A server or welding set sold to a business customer creates no repair obligation under this directive, although the same model sold to a private buyer does. The directive is fully harmonized (Article 3), so member states cannot add stricter or looser rules within its scope, while B2B repair terms remain a matter of contract and national commercial law. Industrial manufacturers are affected mainly where they also sell covered products to consumers.

Do we have to repair products we sold before 2026?

Often, yes. The duty attaches when a consumer asks for a repair after the national rules apply, even for units sold earlier, but only for goods that are subject to the repairability requirements of the Annex II ecodesign rules, and only for as long as those requirements run. A washing machine placed on the market after 1 March 2021 is covered. A phone sold before the phone rules applied on 20 June 2025 is not. Check the application date and the spare parts period of the rule for your product group.

Can we still refuse a repair?

Only on narrow grounds, for example when repair is factually impossible. You cannot refuse for purely economic reasons, such as the cost of spare parts, and you cannot refuse because the unit was previously repaired by an independent shop or by the consumer.

What should operations set up first?

Three things, in order: a work-order-based repair workflow with timestamps and statuses, a parts availability and obsolescence plan for covered products, and structured repair records that can prove response times and guarantee extensions.

If repair is about to become a second production line in your plant, run it with the same discipline as the first one. To see how work orders, spare parts, and repair histories live in one system, get in touch with the Fabrico team.